CLA Submits Comments on NMP Regulation
CLA submitted comments on EPA’s Proposed Rule for regulating n-Methyl-2-pyrrolidone (NMP) under the Toxic Substances Control Act (TSCA). TSCA exempts chemical substances used as pesticides from regulation, but NMP may be produced as a TSCA-regulated substance and later used in pesticide manufacture. CLA's comments address how the proposed rule would impact NMP use and the need for a Workplace Chemical Protection Plan (WCPP) in pesticide production. Pesticide registrants are committed to worker safety and can comply with a WCPP to manage NMP risks. CLA requests that, if necessary, EPA provide ample time for registrants to transition to other solvents without disrupting the supply chain or increasing regulatory burden.
Read the full comments here.